How does Ascent360 define email permission for contacts under CASL?

Email contacts that are known Canadians will be processed under CASL rules. Canadians are identified if they have a known address in Canadian territory or if they have a “.ca” email address.

Here's how their email permission is determined:

  • If they have explicitly subscribed or unsubscribed, we consider this a “hard” email permission and the subscriber will stay with that email permission status unless they change it. 
  • If they have never explicitly subscribed or unsubscribed, we consider this a “soft” email permission. If they have made a purchase within the last 23 months, we consider them contactable, or a “soft” yes because there is an implied business relationship because of the financial transaction. This allows them to be contacted by email for up to two years after that point.
  • If their last financial purchase was more than 23 months ago, they are no longer considered contactable and we treat them as a “soft” unsubscribe.
  • Similarly, if a soft opt-in or opt-out explicitly unsubscribes or subscribes, their subscription settings change to a hard no or hard yes.

Last Financial Purchase Date

Current Email Permission

Hard No

Hard Yes

Soft Yes

Soft No

23+ months ago

Not contactable


Becomes Soft No and not contactable

Not contactable

Less than 23 months ago

Not contactable



Becomes Soft Yes and contactable

Please note:

If any transaction data, specifically around a financial purchase date, was not being sent to Ascent360 correctly, that would impact the customer’s email permission for any contacts being processed under CASL rules. Because of this, a lack of transaction data would show more people as 'soft' unsubscribes than those that are.